David L. Taft Jr. v. Iowa District Court for Linn County
879 N.W.2d 634
| Iowa | 2016Background
- David Taft, civilly committed under Iowa's Sexually Violent Predator Act after convictions for sexual offenses, was confined at CCUSO and remained in Phase II of its five‑phase treatment program.
- CCUSO program advancement and placement in Phase V (transitional release) depend on treatment progress and statutory suitability criteria in Iowa Code § 229A.8A(2).
- At his 2013 annual review Taft sought a final hearing for discharge or placement in transitional release; the district court denied a final hearing, finding he failed to rebut the presumption of continued commitment.
- Taft challenged two statutory suitability criteria—(d) treatment‑provider acceptance of a relapse prevention plan, and (e) no major discipline reports for six months—as violating due process and equal protection.
- The district court held Taft did not meet multiple other suitability criteria and questioned the reliability of Taft’s expert report; it ruled the constitutional challenge was not ripe.
- On certiorari the Iowa Supreme Court affirmed, holding the constitutional challenges were not ripe because relief for Taft would not alter the district court’s disposition given the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §229A.8A(2)(d) (treatment‑provider acceptance of relapse plan) and (e) (six months with no major discipline reports) violate substantive due process | Taft: the criteria impose unlawful preconditions that impermissibly impede liberty and are unrelated to dangerousness | State: criteria regulate suitability for transitional release; placement also depends on treatment phase and program rules; no present injury here | Court: Not ripe—Taft would not qualify under other criteria and relief would not change outcome of review; declined to reach constitutionality |
| Whether the claim presents a justiciable controversy (ripeness) | Taft: challenge may affect future liberty and warrants review now | State: challenge is speculative because suitability is only one of multiple prerequisites and Taft remains in Phase II | Court: No live controversy; speculative future injury; ripeness doctrine bars review |
| Whether court should address evidence‑related rulings from annual review (reliability of expert report) | Taft: sought certiorari on evidentiary standard application and constitutionality | State: evidentiary findings and overall risk determination stood independent of challenged statutory criteria | Court: affirmed district court findings and did not need to resolve constitutional question given disposition |
| Whether antisocial personality disorder alone can support commitment (background note) | N/A (background) | N/A | Court reiterated prior holding that antisocial personality disorder may suffice if individualized inquiry shows it increases likelihood of sexually violent reoffense |
Key Cases Cited
- Taft v. Iowa Dist. Ct., 828 N.W.2d 309 (Iowa 2013) (addressing evidentiary standard for annual review and preservation of constitutional challenge)
- In re Det. of Matlock, 860 N.W.2d 898 (Iowa 2015) (constitutional challenges reviewed de novo)
- State v. Wade, 757 N.W.2d 618 (Iowa 2008) (ripeness and present controversy requirement)
- State v. Sluyter, 763 N.W.2d 575 (Iowa 2009) (ripeness and direct threat standard)
- Swanson v. Civil Commitment Unit for Sex Offenders, 737 N.W.2d 300 (Iowa 2007) (behavioral reports and treatment progression are part of cognitive‑behavioral treatment, not due process violations)
- In re Det. of Barnes, 689 N.W.2d 455 (Iowa 2004) (antisocial personality disorder can support civil commitment when individualized showing of dangerousness exists)